- 3 - (4) How much gain did petitioners realize from the sale of real property located at 400 Crow Canyon Drive, Folsom, California? (5) Are petitioners liable for the addition to tax for negligence under Section 6653(a)(1) for 1988? (6) Are petitioners liable for the addition to tax for substantial understatement of tax liability under section 6661 for 1988? (7) Are petitioners liable for the accuracy-related penalty under section 6662(a) because of negligence or substantial understatement of income tax for 1989? Some of the facts have been stipulated and are found accordingly. The stipulation of facts and attached exhibits are incorporated herein by this reference. Petitioners, Maurice E. Hodgkins and Barbara J. Hodgkins, resided in Sacramento, California, at the time they filed their petition. For convenience we have divided this case by issues. 1. Chancery Court FINDINGS OF FACT While petitioners' names are on the marquee, the leading role in this case was played by petitioner husband's brother, John Hodgkins (John). They trusted John, and he directed them in their financial affairs, told them which documents to sign, kept their books, and supplied the figures for their tax returns. AndPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011